NHTSA Engineering Analysis EA14003

On January 31, 2014, the Office of Defects Investigation (ODI) opened this investigation as PE14-003 based on 18 reports from consumers alleging the harness buckle on their convertible or booster car seat was difficult to unlatch or would not unlatch. Separately, ODI's investigation of harness buckles (see EA13-001) in Graco Children's Products, Inc. (Graco), revealed that the Evenflo Company, Inc. (Evenflo) also used ?QT1 and ?QT3 harness buckles supplied by AmSafe Commercial Products, Inc. in car seats that Evenflo produced.On February 7, 2014 Graco submitted a Defect Information Report (DIR) to recall approximately 3.7 million Graco convertible and booster car seats produced with QT1 and QT3 buckles. Graco did not, at that time, recall its Rear Facing Infant (RFI) seats that used the same buckles.On April 2, 2014, Evenflo submitted a DIR to recall approximately 1.3 million convertible and booster car seats produced with QT1 and QT3 buckles. Like Graco, Evenflo excluded its RFIcar seats from this recall.On June 27, 2014, Graco submitted a DIR which expanded its earlier recall to include approximately 1.9 million Graco RFI car seats produced with QT1 buckles. Graco also committed to conduct a Customer Service Campaign with notification to registered consumers to replace the QT3 harness buckles.On July 7, 2014 ODI upgraded this investigation to Engineering Analysis EA14-003 to continue its investigation concerning Evenflo's RFI car seats. On August 29, 2014, in response to an ODI information request, Evenflo disputed that a safety risk was present in the buckles and claimed that in an emergency situation the entire car seat could be removed from the vehicle, with the child inside.On October 14, 2014, the Agency contacted Evenflo, and advised that the Agency was prepared to send a Recall Request Letter if the company did not recall the RFI. As stated to Evenflo, it was the Agency's position that the car seats should be recalled because the same QT1 buckles had alread